DISCLOSURE: REVENUE SHARING

MUTUAL FUNDS

Through our national network of registered representatives and financial advisors (together, "advisors"), Commonwealth offers a broad selection of more than 9,000 mutual funds, many of which offer multiple share classes. Some of the companies that advise or distribute the mutual funds that we offer engage in activities designed to facilitate the distribution of their products. In particular, some mutual fund affiliates assist our advisors in becoming more knowledgeable about their mutual funds through marketing activities and by offering educational programs, including, but not limited to, attendance by fund representatives at Commonwealth conferences and events, one–on–one marketing, and due diligence presentations.

In return for assistance in facilitating the activities described above, Commonwealth receives payments, called revenue sharing, from the funds’ advisors or distributors. These revenue–sharing payments are in addition to commissions, annual service fees (known as 12b–1 fees), and other fees and expenses disclosed in the fee table in a fund’s prospectus. The revenue–sharing payments, however, are paid out of the investment advisor’s or other fund affiliate’s assets—not from the fund’s assets—and therefore would not appear as an item in a fund’s expense table. No portion of the revenue–sharing payments to Commonwealth is made by means of brokerage commissions generated by funds whose affiliates make revenue–sharing payments.

None of the revenue–sharing payments received by Commonwealth is paid or directed to any of our advisors who sell mutual funds to their clients. Further, our advisors do not receive additional compensation for sales of mutual funds whose affiliates make revenue–sharing payments to Commonwealth. Because Commonwealth's advisors receive no direct increase or change in compensation for selling shares of mutual funds whose affiliates make revenue–sharing payments to Commonwealth, we do not believe that the advisors are subject to conflicts of interest arising from revenue–sharing payments made to Commonwealth. The marketing and educational activities paid for with revenue sharing, however, could lead our advisors to focus more on the funds whose affiliates make revenue–sharing payments to Commonwealth—rather than on funds whose affiliates do not assist advisors in becoming familiar with their funds—when recommending mutual fund investments to their clients.

Commonwealth does not maintain a "recommended" list of mutual fund families based on participation in revenue–sharing arrangements but offers a selection of many funds.

The mutual fund families that participate in the revenue–sharing programs described above are:

AB

Allianz Global Investors

American Funds

BlackRock

Columbia

Deutsche Asset

Eaton Vance

Federated

Fidelity Advisor

Franklin Templeton

Goldman Sachs

Hartford Funds

Invesco

Ivy

John Hancock

J.P. Morgan

Legg Mason

Lord Abbett

MainStay

MFS

Natixis

Nuveen

Oppenheimer

PIMCO

Pioneer

Principal

Prudential Investments

Putnam

Thornburg

Virtus Investment Partners

Commonwealth’s revenue–sharing arrangements, including the amounts paid by affiliates of the mutual funds listed above, vary. Generally, Commonwealth and fund affiliates determine the amount of revenue–sharing payments in advance. Payments are made quarterly during or after the period covered by the arrangement. Except for the arrangement with American Funds Distributors, the revenue–sharing payments are fixed and not based on assets under management or sales that occur during the period covered by the revenue–sharing arrangements.

The arrangement with American Funds Distributors provides that the amount of revenue–sharing payments will be based upon a number of factors set forth in American Funds’ prospectuses, including an assessment of the quality of the relationship with Commonwealth during the period covered by the arrangement. The level of payments in any given year varies and represents the sum of (a) up to 10 basis points (0.10 percent) of the previous year's American Funds sales and (b) up to 2 bps (0.02 percent) of customer assets. Sales to and assets invested in retirement fiduciary accounts play no role in determining the amount of payments made by American Fund Distributors.

Some participating fund families may make additional payments to Commonwealth for attendance at various educational meetings hosted by Commonwealth throughout the year.

Some mutual funds that we sell may also offset certain transaction costs that would otherwise be borne by an advisor for clients who choose to custody their assets with Fidelity Clearing & Custody Solutions® (FCCS), which provides clearing, custody, and other brokerage services to Commonwealth through National Financial Services LLC (NFS)*—a wholly owned subsidiary of Fidelity Investments. These transaction charges are up to $15 per transaction in connection with each purchase of a mutual fund by a client, depending on the account and/or transaction type. We believe that this offset does not compromise the advice that your advisor gives you.

Additionally, NFS offers a "No Transaction Fee" program with more than 3,600 no–load mutual funds. Participating mutual fund sponsors pay NFS a fee to participate in the program; and a portion of this fee is shared with Commonwealth. None of these additional payments is paid to any advisors who sell these funds.

Variable insurance programs

Commonwealth also offers many variable insurance products. Some of the insurance sponsors of the variable insurance products that we offer engage in activities that are designed to help facilitate the distribution of their products; some of these sponsors assist our advisors in becoming more knowledgeable about their products by engaging in marketing activities and offering educational programs (including, but not limited to, attendance by sponsor representatives at Commonwealth conferences and events, one–on–one marketing, and due diligence presentations).

In return for assistance in facilitating the activities described above, Commonwealth receives additional compensation, called revenue sharing, from certain insurance sponsors. These revenue–sharing payments are in addition to commissions and other fees and expenses disclosed in the variable annuity’s prospectus and Statement of Additional Information (“SAI”). These revenue–sharing payments, however, are paid out of the sponsor’s assets—not from the variable insurance product’s assets—and therefore would not appear as an item in a product’s expense table. No portion of these revenue–sharing payments to Commonwealth is made by means of brokerage commissions generated by the variable annuity.

It is important to understand that none of the revenue–sharing payments received by Commonwealth is paid or directed to any of our advisors who sell variable insurance products to their clients, and our advisors do not receive additional compensation for sales of variable insurance products whose sponsors make revenue–sharing payments to Commonwealth. Because Commonwealth’s advisors receive no direct increase or change in compensation for selling variable insurance products whose sponsors make revenue–sharing payments to Commonwealth, we do not believe that they are subject to conflicts of interest arising from revenue–sharing payments to Commonwealth. The marketing and educational activities paid for with revenue sharing, however, could lead our advisors to focus more on those products whose sponsors make revenue–sharing payments to Commonwealth—as opposed to products whose sponsors do not assist advisors in becoming familiar with their products—when recommending variable insurance products to their clients.

Commonwealth does not maintain a “recommended” list of variable insurance products.

The following variable insurance sponsors participate in this revenue–sharing program:

Allianz Life

AXA Distributors

Brighthouse Financial

CUNA Mutual Group

Global Atlantic

Great West

Jackson National Life

Lincoln National

Nationwide

New York Life

Pacific Life

Securian Financial

Symetra

While the revenue–sharing arrangements that Commonwealth has entered into with insurance sponsors vary, each sponsor pays Commonwealth a fixed annual fee. The amount of the fixed annual fee is determined by Commonwealth and the particular insurance sponsor in advance and is paid quarterly during the period covered by the arrangement. Revenue–sharing payments are not based on sales that occur during the period covered by the revenue–sharing arrangements with insurance sponsors. Some of the participating insurance sponsors may also make additional payments to Commonwealth for attendance at various educational meetings hosted by Commonwealth throughout the year.

VARIABLE UNIVERSAL LIFE AND UNIVERSAL LIFE INSURANCE PROGRAMS

Commonwealth also offers variable universal life ("VUL") and universal life ("UL") insurance products. Some of the insurance sponsors of the VUL and UL insurance products that we offer engage in activities that are designed to help facilitate the distribution of their products; some of these sponsors assist our advisors/insurance agents in becoming more knowledgeable about their products by engaging in marketing activities and offering educational programs (including, but not limited to, attendance by sponsor representatives at Commonwealth conferences and events, one–on–one marketing, and due diligence presentations).

In return for assistance in facilitating the activities described above, Commonwealth receives additional compensation, called revenue sharing, from certain insurance sponsors. These revenue–sharing payments are in addition to commissions and other fees and expenses disclosed in the insurance product’s prospectus, SAI, and/or contract. These revenue–sharing payments, however, are paid out of the sponsor’s assets—not from the insurance product’s assets—and therefore would not appear as an item in a product’s expense table. No portion of these revenue–sharing payments to Commonwealth is made by means of commissions generated by the insurance product.

It is important to understand that none of the revenue–sharing payments received by Commonwealth is paid or directed to any of our advisors/insurance agents who sell the insurance products to their clients, and our advisors/insurance agents do not receive additional compensation for sales of insurance products whose sponsors make revenue–sharing payments to Commonwealth. Because Commonwealth’s advisors/insurance agents receive no direct increase or change in compensation for selling insurance products whose sponsors make revenue–sharing payments to Commonwealth, we do not believe that they are subject to conflicts of interest arising from revenue–sharing payments to Commonwealth. The marketing and educational activities paid for with revenue sharing, however, could lead our advisors/insurance agents to focus more on those insurance products whose sponsors make revenue–sharing payments to Commonwealth—as opposed to insurance products whose sponsors do not assist advisors/insurance agents in becoming familiar with their products—when recommending insurance products to their clients.

While the arrangements with each insurance sponsor may vary, each VUL and UL insurance sponsor may pay between 10 percent and 25 percent of target VUL and UL premiums. Some of the participating insurance sponsors may also make additional payments to Commonwealth for attendance at various educational meetings hosted by Commonwealth throughout the year.

Pacific Life participates in the revenue–sharing program.

NONPUBLICLY TRADED PRODUCTS

Commonwealth, through its advisors, also offers several nonpublicly traded products, including nonlisted real estate investment trusts ("REITs"), limited partnerships ("LPs"), business development companies ("BDCs"), closed-–end funds, Interval Funds, 1031 exchange programs, hedge funds and fund of funds, managed futures, tax credit programs, oil and gas programs, venture capital funds, and private equity funds. Some of the issuers of the nonpublicly traded products that we offer engage in activities that are designed to help facilitate the distribution of their products; some of these issuers assist our advisors in becoming more knowledgeable about their products by engaging in marketing activities and offering educational programs (including, but not limited to, attendance by sponsor representatives at Commonwealth conferences and events, one–on–one marketing, and due diligence presentations). Consistent with prudent product approval practices, Commonwealth conducts or causes to be conducted a due diligence analysis of these products prior to making them available to the public through its advisors.

In return for assistance in facilitating the activities described above, Commonwealth receives due diligence fees as well as additional compensation, called revenue sharing, from certain product issuers. These revenue–sharing payments are in addition to commissions and other fees and expenses disclosed in the product’s private placement memorandum and other offering documents.

Although the arrangements with each sponsor may vary, each product sponsor may pay a due diligence, stockholder servicing, or marketing allowance fee of either a) up to 70 bps (0.70 percent) annually on assets held at the sponsor; or b) up to 200 bps (2percent) on the gross amount of each sale, depending on the product. None of these additional payments, however, is paid or directed to any advisor who sells these products. Commonwealth advisors do not receive a greater or lesser commission for sales of these products from which Commonwealth receives revenue–sharing payments. Because Commonwealth's advisors receive no direct increase or change in compensation from selling one product over another, we do not believe that they are subject to conflicts of interest arising from the due diligence and/or revenue–sharing payments to Commonwealth. The marketing and educational activities paid for with revenue sharing, however, could lead our advisors to focus more on those products whose sponsors make revenue–sharing payments to Commonwealth—as opposed to products whose sponsors do not assist advisors in becoming familiar with their products—when recommending nonpublicly traded products to their clients.

Additionally, Commonwealth receives continuous revenue–sharing payments from NFS that are derived from certain types of transactions, positions, and assets in client accounts held at NFS. Commonwealth also maintains a Core Account Sweep Program with NFS. This program creates substantial financial benefits for Commonwealth as detailed on the firm’s Core Account Sweep Program webpage. Commonwealth’s agreement with NFS also provides that NFS shall pay to Commonwealth incentive credits for reaching certain net–flow percentage asset targets and rebates of core fees paid to NFS by Commonwealth.

Additionally, NFS offers an NTF program composed of no–load mutual funds. Participating mutual fund sponsors pay a fee to NFS to participate in the NTF program, and a substantial portion of this fee is shared with Commonwealth. Funds available through the NTF program often contain higher internal expenses than mutual funds that do not participate in the NTF program.

RetIREMENT PLAN RECORDKEEPERS

Commonwealth also offers services to retirement plans. Some retirement plan recordkeepers engage in activities to promote their products and services. Some of these sponsors assist our advisors in becoming more knowledgeable about their products by engaging in marketing activities and offering educational programs (including, but not limited to, attendance by sponsor representatives at Commonwealth conferences and events, one–on–one marketing, and due diligence presentations).

In return for assistance in facilitating the activities described above, Commonwealth receives additional compensation, called revenue sharing, from certain retirement plan recordkeepers. These revenue–sharing payments are in addition to commissions and other fees and expenses otherwise payable to Commonwealth. These revenue–sharing payments, however, are paid out of the sponsor’s assets—not from any securities product’s assets—and therefore would not appear as an item in a product’s expense table. No portion of these revenue–sharing payments to Commonwealth is made by means of brokerage commissions generated by any products.

It is important to understand that none of the revenue–sharing payments received by Commonwealth is paid or directed to any of our advisors who sell retirement plan products to their clients, and our advisors do not receive additional compensation for retirement plans at recordkeepers that make revenue–sharing payments to Commonwealth. Because Commonwealth’s advisors receive no direct increase or change in compensation for retirement plans at record-keepers that make revenue–sharing payments to Commonwealth, we do not believe that they are subject to conflicts of interest arising from these payments to Commonwealth. The marketing and educational activities paid for with revenue sharing, however, could lead our advisors to focus more on those recordkeepers that make revenue–sharing payments to Commonwealth—as opposed to recordkeepers that do not assist advisors in becoming familiar with their services—when recommending a retirement plan recordkeeper to their plan clients.

Commonwealth does not maintain a “recommended” list of retirement plan recordkeepers.

The following retirement plan recordkeepers participate in this revenue–sharing program:

American Funds Distributors, Inc.

Empower Retirement

Franklin Templeton Distributors, Inc.

Janus Capital Group, Inc.

Legg Mason Investor Services, LLC

Lord, Abbett & Co. LLC

MassMutual Life Insurance Company

Nationwide Financial

PayChex

Principal Funds Distributors, Inc.

Thornburg Investment Management, Inc.

TransAmerica Life Insurance Company

T. Rowe Investment Services, Inc.

While the revenue–sharing arrangements that Commonwealth has entered into with retirement plan recordkeepers vary, each sponsor pays Commonwealth a fixed annual fee. The amount of the fixed annual fee is determined by Commonwealth and the particular retirement plan recordkeeper in advance and is paid quarterly during the period covered by the arrangement. revenue–sharing payments are not based on sales that occur during the period covered by the revenue–sharing arrangements with retirement plan recordkeepers. Some of the participating retirement plan recordkeepers may also make additional payments to Commonwealth for attendance at various educational meetings hosted by Commonwealth throughout the year.

For revenue–sharing information about a specific fund family or sponsor, please contact Commonwealth at 800.237.0081.

*Fidelity Clearing & Custody Solutions® (FCCS) is an independent company, unaffiliated with Commonwealth. FCCS is a service provider to Commonwealth and provides clearing, custody, and other brokerage services to Commonwealth through National Financial Services LLC (NFS), member NYSE, SIPC.